LifesaverSIM and its owner company Impulsis OÜ (hereinafter referred to as “the Company”, “we”, “us”, or “our”) recognize that our customers value their right to privacy and want to be assured that any personal information that they provide to us will be used in accordance with their wishes. The Company is committed to ensuring that you are fully informed as to how your personal information will be used and that it will be kept secure.

This Privacy Policy applies to the ecosystem of applications, websites, software, and related services offered under the LifesaverSIM brand (collectively referred to as the “Service”). This includes, but is not limited to, the LifesaverSIM mobile application, our websites (such as www.lifesaversim.com), administrative portals, and any other LifesaverSIM-branded service that refers or links to this policy. By accessing or using the Service, you signify your acceptance of the terms of this Privacy Policy.

1. What Information Do We Collect?

The Company may collect personal information from you relating both to your identity and personal preferences as well as to our products and services. We will endeavor only to collect such information as is necessary for the stated purpose for which we are collecting it.

• Within an Application: Account information (Google, Apple, email login); In-app profile nickname (visible to others); and Non-personal data, such as learning telemetry, assessments logs, and progress history.

• On our Websites: Name, email, phone; Organization name, type, role, occupation, skill level; Country of residence; User or account IDs; and any other information you voluntarily provide in free-text fields, such as in messages or inquiries.

• Through Other Interactions: Information provided during communications, customer support, email/mail campaigns, newsletters, registrations, purchases, resumes, surveys, and Usage Data collected automatically during your interaction with our services.

2. Purposes and Legal Basis for Processing Information

We process your information for purposes that include product registration, account management, product purchases, communication about products, internal analysis, and improving our services. We rely on the following legal bases to process your data:

• Performance of a Contract: To provide you with our services, manage your account, and fulfill your purchases.

• Legitimate Interest: For our legitimate business interests, such as for internal analysis, service improvement, and security, provided these do not override your rights and interests.

• Consent: For activities such as sending marketing communications or newsletters, where we will ask for your explicit consent.

• Legal Obligation: To comply with applicable laws and legal requirements.

3. Sharing of Information with Third Parties

We do not sell or trade your personal information. Sharing of your data is limited and occurs only in the following situations:

• With Service Providers: We share information with trusted service providers who perform services on our behalf, such as for analytics or marketing. These providers are bound by confidentiality terms.

• With our Core Technology Partner: All personal data we collect is stored and processed on secure cloud infrastructure managed on our behalf by our core technology partner, Thundermark LTD (Ukraine), which is bound by confidentiality terms.

• With Your Organization: If you access the Service via an organization (e.g., license keys, SSO), your organization's administrators may have access to your information. Your organization may also act as a separate controller for the records it manages about you. For those records, contact your organization.

• Where Required by Law: We may disclose your information if legally required to do so.

4. Security

We implement and maintain appropriate technical and organizational security measures designed to protect the security of any personal information we process. These measures are aimed at ensuring your information is stored in a secure environment with access limited to designated staff and processors.

5. Cookies

Cookies, SDKs, and similar technologies may be used. Full details and preference management are in our separate Cookie Policy.

6. Links

Links to third-party websites are not governed by this policy. Review their policies when you visit them.

7. Chat Rooms and Newsgroups

If community features are available, information shared may be public. Avoid posting sensitive data.

8. Children

Our services are not designed for children. Children under applicable legal age should not provide personal information.

9. How Can You Access and Control Your Information?

Depending on your location, you may have the following rights regarding your personal information:

• The right to access, correct, or update your information.

• The right to request deletion (erasure) of your information.

• The right to object to or restrict the processing of your information.

• The right to data portability.

• The right to withdraw consent at any time.

Residents of California may have additional rights under the CCPA/CPRA. To exercise any of these rights, please contact us at support@lifesaversim.com (subject: Privacy Request).

10. Retention and Storage of Information

The Company retains personal data only for as long as necessary for the purposes for which it was collected. Our retention schedules are as follows:

• We retain all data associated with your in-app account, including personal data and non-personal data, for as long as your account remains active. Upon the deletion of your account, this data will be permanently erased or anonymized.

• Personal data collected through our websites is retained for a period of three (3) years following your last interaction with us.

• Notwithstanding the above, we may retain certain information for a longer period where we are subject to a legal obligation to do so (e.g., for tax, accounting, or contract laws).

In some instances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely.

Data is processed and stored on secure cloud infrastructure located within the European Union, managed by our core technology partner in Ukraine. Data may therefore be processed in the EU/EEA, UK, US, Ukraine, and other locations, with appropriate safeguards, such as the use of Standard Contractual Clauses, for international transfers.

11. Changes to This Policy

The Company reserves the right to amend this Privacy Policy from time to time. Any updates will be posted on this page and will not have retrospective effect.

12. Business Transfers

In the event that the Company is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. This Privacy Policy will apply to your information as transferred to the new entity.

13. Contact Us

If you have any questions, please contact us with the subject line "Privacy Question" at support@lifesaversim.com.

Impulsis OÜ
Aiandi tänav 9/3-38
12915 Tallinn, Estonia
Company/Registry No.: 14432878

This policy was last updated on August 31, 2025.